Video Star Entertainment, LLC 16 Appleway Drive #6 Kalispell, MT 59901 info@videostarentertainment.com Cell Phone: 406-212-8846 Date: 01-10-2016 US Department Of Transportation Federal Aviation Administration 800 Independence Ave SW Washington DC 20591

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012(the reform act) and CFR Part 11, Video Star Entertainment, LLC, owner and operat or of Small Unmanned Aircraft Systems (UASs), request to be exempted from the Federal Aviation Re gulations {FAR) listed below so that Video Star Entertainment, LLC may operate UASs commercially in airspace regulated by the FAA, as long as such operations are conducted within and under the condi tions outlined herein or as may be established by the FAA as required by Section 333. Video Star Entertainment, LLC is co-owned by Jordan M Lister and Jessica L Lister. Video Star Entertainment, LLC will secure a PIC as operator wi th appropriate licensure as stipulated by the Secti on 333 exemption requirements. All operations performe d will be performed with public’s safety and right to privacy safe-guarded at all times. As described below, the requested exception would p ermit the operation of light weight (less than 55 lbs. total takeoff weight) UASs under controlled co nditions for commercial use by a certified private pilot thereby enhancing safety and fulfilling the Secreta ry of Transportation's ( the FAA Administrator's) responsibility to" establish requirements for safe operation of such aircraft systems in national airs pace systems." Section 333(c), of the Reform Act. Video Star Entertainment, LLC’s video UASs are roto rcrafts weighing less than 55 pounds including payload. (The DJI Phantom 3 Professional) They oper ate at a speed less than 50 knots and have the capability to hover and move in the vertical and ho rizontal plane simultaneously. UASs have an auto return to launch point when battery power is under 25%. The UAS will operate within the line of sight with in a protected flight area as described below and at 200 feet AGL or less with an observer locate d close at hand as to make voice communication possib le. These operations will not create a hazard to users of the nation airspace, public nor the enviro nment.Video Star Entertainment, LLC respectfully requests the grant of an exception to the following specifi c

sections of the Title 14 Code Federal regulations a 11owing it to operate lightweight UASs for commerci al use, 14 CFR 21,subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109, 91.119, 91.121,91.151,(a), 91.203(a) &{b},91.405(a),91.407( a)(1), 91.409(a)&(b). Video Star Entertainment, LLC submits this applicat ion in accordance with the Reform Act, 112 P.L. 95 331-334, seeking relief from any current applicable FAR’s operating to prevent Video Star Entertainment, LLC future commercial use of small U ASs to operate in the national airspace system (NAS) as described below. The Reform Act section 33 2 provides for such integration of civil unmanned aircraft into our NAS as it is in the public’s inte rest to do so. Video Star Entertainment, LLC’s UASs meet the definition of “small unmanned aircraft” as defi ned in Section 331 and therefore the integration of these UASs are expressly contemplated by the Reform Act. Video Star Entertainment, LLC would like to operate its light weight UASs prior to the time per iod by which the Reform Act requires the FAA to promulgate rules governing such aircraft. The Reform Act direct the Secretary of Transportati on to consider whether certain unmanned aircraft systems may operate safely in the national airspace before completion of the rule making required under Section 332 of the Reform Act. In making this determination, the Secretary of Transportation is required to determine which UASs do create a hazard to users of the NAS or the public or pose a threat to national security in light of the following: - The UASs size, speed, weight and operational capa bility - Operation of the UASs in close proximity to airpo rts and populated areas - Operation of the UASs within visual line of sight of the operator Reform Act 333(a). If the secretary determines that such vehicle “may operate safely in the national airspace system, the secretary shall establish requ irements for the safe operation in national airspac e” Video Star Entertainment, LLC video UASs are rotorc raft weighing less than 55 pounds including payload

. (The DJI Phantom 3 Professional class) They operate at a speed less than 50 knots and have the capability to hover and move in the vertical and ho rizontal plane simultaneously. UASs have an auto return to launch point when battery power is under 25%. The UAS will operate within the line of sight with in a protected flight area as described below and at 200 feet AGL or less with an observer locate d close at hand as to make voice communication possib le. These operations will not create a hazard to users of the nation airspace, public nor the enviro nment. The very small nature of these UASs combined with t he safe guards presented below, will allow for the safe operation greater than that envisioned by Cong ress for the FAA to establish and by exemption allo w commercial operations of UASs to commence immediate ly. Also due to the size of UASs and the areas and altitudes they will operate approval of this ex ception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk managementprocess. Given the clear direction given in Section 333 of the Reform Act, the authority contained in the

Federal Aviation Act, as amended, the strong equiva lent level of enhanced safety, reduced emissions utilizing UASs verses traditional aircraft as well as the economic impact of greatly reducing the cost of aerial photography thereby benefiting the greater p ublic's interest. Accordingly, the applicant reques ts that the FAA grant the requested exemption without delay. The following will be considered as the binding lim itation on operations of Video Star Entertainment, LLC, 1. Flights will only occur in the day time hours 2. Flights will be operated in the line of sight of the operator (PIC) and Observer (VSO) 3. Flights will be terminated at any time weather a nd wind deteriorate to "unsafe for flight" by manufacturers recommendations 4. The UASs will weigh less than 55 lbs. 5. Flights will be operated at 200 feet AGL or less

. 6. Crew will be at a minimum of operator (PIC) and an observer and/or camera operator (VSO) 7. Operator and crew will remain in contact during the flight operation 8. The UASs operator will perform a check of the fl ight area and make certain of the safety of all per sons in the area 9. Consent will be obtained from all persons with i n the video capabilities of the units to further re duce the chance of violating anyone's privacy 10. All required FAA clearances will be obtained an d distances from airports strictly observed. 11. All UASs will have the capability to return aut omatically to the operator in a safe manner with th e auto return function checked and working. 12. When operated in conjunction with fishing vesse ls in the gulf, a chase boat will be assigned to operate the UASs at a safe distance from the main f ishing boat. 13. Flights will only operate in VFR conditions. 14. UASs have a function on the control to tell ope rator the distance away from the operator and its battery power remaining. 15. Flight team will communicate by voice and the u se of two-way radio if the area is too great to hea r voice from all team members. 16. UASs will be used to video private outings and functions, boating, jet skiing, kayaking, fishing t rips and sporting events from a safe distance.17. When operating over or near water the UASs will be equipped with flotation devices so that

recovery can be made as to prevent lithium battery exposure to the water table.

14 CFR part 21Subpart H: Airworthiness Certificate 14 CFR 91.7(a}, 91.203(a)(l) Subpart H, entitled Airworthiness Certificates, sets forth requirementsfor procurement of necessary certificates in relat ion to FAR 91.203(a)(l). The size, weight and defined a rea of operations for Video Star Entertainment, LLC UASs flights permits exception from Part 21 because they meet an equivalent level of safety pursuant t o Section 333 of the Reform Act. The FAA is authorize d to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in consideration o f weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Video Star Entertainment, LLC meets or exceeds each of these elements As of March 23, 2015 the FAA has stated that it wil l automatically grant a "blanket" COA for flights a t or under 200 AGL to any UASs operator with a section 3 33 exemption. 14 CFR 91.203(a & b) provides for carrying of civil aircraft certifications and registrations. These a re inapplicable for the same reasons stated above. The equivalent level of safety will be achieved by maintaining such certifications and registrations a t Video Star Entertainment, LLC operations center. 14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contempl ated by FAR's this regulation is inapplicable. 14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in A ircraft 14 CFR 91.9(b)(2) requires an aircraft flight manua l in the aircraft. As there are no pilots or passen gers, and given the size of the UASs this regulation is i napplicable. An equivalent level of safety will be achieved by maintaining such certifications and reg istrations at Video Star Entertainment, LLC operations center. The FAA has previously issued exemptions to this re gulation in Exemptions No's 8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,1 0602,10700 and 32827. 14 CFR 91.119 Minimum safe altitudes, prescribes sa fe altitudes for operation of civil aircraft. It al lows helicopters to be operated at lower altitudes in ce rtain conditions. Video Star Entertainment, LLC wil l only operate its UASs at or below 200AGL. They will be operated on a well defined AOR that has been carefully reviewed for hazards and minimizes the pr esence of any persons not essential for these operations. Flights will only be over private prope rty that the owner has consented and all persons within this video area also give consent for this f ilming. Compared to flight operations of convention al and traditional aircraft or rotorcraft weighing farmore than 50 lbs, operating below 500 AGL with flammable fuel UASs operations present a far smalle r risk to the public.Approval of these 333 Exemptions allowing commercia l operations of small UASs in the service of aerial

photography will greatly enhance safety by reducingthe overall risk associated with traditional aircr aft. Traditional aerial photography requires large aircr aft with flammable fuel to fly in close proximity o f populated areas and people in general. With the use of small UASs of 55 lbs. or less, battery operated and fling below 200 feet AGL the risk of injury of people on the ground or the crew has been reduced o r almost erased. The granting of the use of these sma ll UASs by Video Star Entertainment, LLC will give the people another avenue to express themselves and to have a video record to share with family and friends forever. Granting Video Star Entertainment, LLC the above ex emption will allow for the expansion of UAS systems into the future for the safe conduct of fre e enterprise and the enjoyment of the masses. Video Star Entertainment, LLC respectfully requests the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by Video Star Entertainment, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 {1958) as amended {the ACT). Respectfully submitted,

Jordan M Lister

Owner Video Star Entertainment, LLC

INTERESTS OF THE PETITIONER The objective is to expand a small video production business into Aerial Video and Photography Service to provide high quality imaging for a variety of co mmercial and public uses, specifically targeting: - Wedding and Special Events coverage - Local news coverage - Video for Real Estate agents - Coverage of Sporting Events

- Interviews of individuals UAS/AERIAL EQUIPMENT OF THE PETITIONER

- DJI Phantom 3 Professional UASsVideo Star Entertainment, LLC only utilizes safe an d reliable UASs. DJI is an industry leader in small UAS

production. DJI UASs are loaded with ground breakin g software enabling the user to set parameters which will not allow flight into controlled airspac e. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as li mit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)